GNI Ofgem Interconnector Licence – consultation on approval of terms for access to the interconnector

Consultation by Gas Networks Ireland

Proposed that the ‘Tripartite Agreement in relation to arrangements at the interconnection point at Moffat’ (between National Grid Gas plc; GNI (UK) Limited; and Gas Networks Ireland) will be submitted to Ofgem for approval as terms for access as required under the Gas Networks Ireland’s interconnector licence from Ofgem.

Background to the consultation

As a result of a restructure of assets, Gas Networks Ireland (GNI) sought and were granted a Gas Interconnector Licence by Ofgem in June 2020. The licence granted to GNI, authorises the participation of GNI in the operation of the Moffat Interconnector System from the limit of the UK Territorial Waters in the United Kingdom to the limit of the UK Continental Shelf. ((GNI (UK) also holds an interconnector licence from Ofgem in respect of that part of the Moffat Interconnector System between Moffat in Scotland to the end of UK Territorial Waters.)

One of the obligations of GNI’s licence is the requirement to submit for approval to Ofgem “Access Rules” for the interconnector, as outlined in standard licence condition 11A of the Ofgem Gas Interconnector Licence. Similar to the methodology that GNI (UK) take to satisfy this condition in GNI (UK)’s interconnector licence, GNI are proposing to use the ‘Tripartite Agreement in relation to arrangements at the interconnection point at Moffat’ between GNI (UK), National Grid Gas and GNI to satisfy the requirements of the condition. There are no changes proposed to be made to the existing tripartite agreement and the proposal to adopt the tripartite agreement as GNI’s Access Rules under its interconnector licence from Ofgem will not necessitate any impact to the daily shipper processes as outlined in the Code of Operations.

Consultation

Standard Licence Condition 11A “Approval of terms for access to the licensee’s interconnector” requires GNI to prepare and submit for approval by Ofgem a statement, setting out GNI’s Access Rules for the interconnector.
The Access Rules must include:
 
a) arrangements for maximising the available interconnector capacity, including:
  • the methodology for the calculation of interconnector capacity;
  • the provision of virtual capacity for a counter-flow of gas on the interconnector;
  • the volume of capacity offered on a firm basis; and
  • any additional capacity offered on an interruptible basis to maximise cross-border trade;

b) arrangements for users to obtain interconnector capacity at appropriate timescales, including, where relevant, the auction rules and procedures for nominating gas flows against the capacity;
c) arrangements for the management of congestion, including procedures for licensees to resell or make available to other users unused interconnector capacity and for users to transfer or resell interconnector capacity;
d) arrangements in the event that the licensee curtails, withdraws or is unable to provide available capacity;
e) arrangements for any ancillary services, such as balancing arrangements, including where these are offered by third parties, including agents; and
f) any general terms and conditions that a user must accept in order to obtain interconnector capacity.

GNI propose that the Tripartite Agreement in relation to arrangements at the interconnection point at Moffat between National Grid Gas plc, GNI (UK) Limited and Gas Networks Ireland; together with the accompanying ‘GNI Access Rule Mapping Table’, which identifies the areas within the tripartite agreement which satisfy the licence condition obligations, will be submitted to Ofgem as GNI’s Access Rules as per the terms of standard licence condition 11A of the Ofgem Gas Interconnector Licence.
 
In advance of the submission, GNI invites any persons who may have a direct interest in the access rules to view the proposal and, should they so wish, make written representations on same.
 
GNI hereby invites interested parties to submit written representations to marketdevelopment@gasnetworks.ie by 29th January 2021.
 
  1. Tripartite Agreement in relation to arrangements at the interconnection point at Moffat
  2. GNI Access Rules Mapping Table